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HMRC internal manual

Tonnage Tax Manual

HM Revenue & Customs
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Tonnage tax groups: Merger

Between non-qualifying and qualifying non-tonnage tax groups or companies

Where there is a merger between a non-qualifying company or group (NQ) and a qualifying non-tonnage tax company or group (QNT), and if NQ is the dominant party, then, per paragraph 125, the new group may elect into tonnage tax as from the date of merger.

This is to allow the dominant party, which could never had elected, a chance to reconsider the decision by its newly acquired qualifying company or companies originally not to elect.

Such an election must be made jointly by all qualifying companies in the new group by notice in writing to HMRC within 12 months of the date of merger.


FA00/SCH22/PARA125 (merger between NQ and QNT) TTM17701
FA00/SCH22/PARA126 (meaning of ‘dominant party’) TTM17701
Dominant party TTM12350
Effect of exiting from tonnage tax regime TTM14100
Definitions of NQ and QNT TTM12300